Subject: re: file # S7-8-99

Monroe Securities Inc.
     
47 State Street
     
Rochester, NY 14614
     
800-766-5560
     
     
                                April 1, 1999
     
Jonathan G. Katz, Secretary
Securities and Exchange Commission
        via E-Mail
     
Dear Mr. Katz:
     
We are opposed to the proposed rules even though we are and will be Y2K 
compliant.  We view this as part of the regulatory Juggernaut (i.e. tidal 
wave) that began a few years ago.
     
In our opinion, basing who would be swept into heavy Y2K reporting on capital 
or net capital requirement is incorrect.  That a firm our size has to do the 
same filings as Merrill Lynch and Pershing (who clears for 600 firms) does not 
seem necessary.
     
The criteria should have been and should be:
1. Self-clearing broker-dealers (we clear through another);
2. How many customer accounts the broker-dealer has (we have a very small 
number).
3. Whether the broker-dealer is willing to advise customers of potential Y2K 
problems and suggest they withdraw their funds and securities if they are 
concerned (we are planning to do so).
     
We pretty much deliberately decided years ago to let the computer revolution 
pass us by and while we use personal computers for some things, few functions 
are date sensitive.  A great many chores are still performed manually with 
calculators or with a computerized spread sheet that doesn't care what the 
date is.  That we should be drawn into this is surprising.
     
There might very well be a Y2K problem.  You were correct to address it. 
However, you went with a shotgun approach instead of using a laser.
     
On a definitely-related subject, your average time estimate of 35 hours for 
completion of Part II of the Y2K report as submitted to the OMB was, in our 
opinion, understated and far too low.
     
Respectfully,
     
Jack Rubens
President